Privacy Policy

KENT FA PRIVACY POLICY
 
Kent County Football Association Limited ("we", "our", "us") takes your privacy very seriously.
 
This Privacy Notice sets out how we use and look after the personal information we collect from you. As the organisation who is responsible for, and controls the processing of your personal data, we are the data controller, and sometimes also the data processor, and will take reasonable care to keep your information secure and to prevent any unauthorised access or use of it. We are required under data protection legislation to notify you of the information contained in this Privacy Notice.
 
We may update this Privacy Notice from time to time and will inform you of any changes in how we handle your personal data as soon as reasonably practicable.
 
It is important that you read and retain this Privacy Notice, together with any other Privacy Notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information and what your rights are under the data protection legislation.
 
Data protection principles 
 
We will comply with data protection law. This says that the personal information we hold about you must be:
1. Used lawfully, fairly and in a transparent way.
2. Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes.
3. Relevant to the purposes we have told you about and limited only to those purposes.
4. Accurate and kept up to date.
5. Kept only as long as necessary for the purposes we have told you about.
6. Kept securely.
 
Information we may collect from you
 
Personal data means any information about an individual from which that individual can be identified. It does not include data where the identity has been removed (anonymous data).
 
We may collect, use, store and transfer some personal data of our participants and their parents or guardians, and other members. The data we collect from participants may include:
 
- name, date of birth and gender; and 
- contact information, such as home address, email address, qualifications, parent/carer contact details and telephone numbers
 
There are certain types of more sensitive personal data which require a higher level of protection, such as information about a person's health or sexual orientation (“special category data”). We may collect and store some special category data for the purposes of the health, wellbeing, welfare and safeguarding of our participants and members. Where we hold this data, it will be with the explicit consent of the participant or, if applicable, the participant’s parent or guardian. Where we need to collect personal data to fulfil our responsibilities and a participant fails to provide that data, we may not be able honour or administer their participation in football. 
 
How is your personal data collected?
 
A participant may give us their personal data by filling in forms or by corresponding with us by post, phone, email, in person, via our website or otherwise. This will typically be provided by a participant’s club by inputting participant details into Whole Game System. Other participants, such as referees, may input their own data into Whole Game System.
 
How the FA and Kent FA uses personal data
 
We will use personal information only for the purposes for which we have been provided with such information. We need participants’ and members’ personal data for the following reasons:
- to manage the County FA.
- to administer leagues.
- to support football clubs. 
- to administer memberships; and
- to deal with sanctions. 
 
Our lawful basis for processing personal data is that we have a contractual obligation to individuals as participants or members to provide the services of a county football association.
 
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Purpose / Processing   Lawful Basis 
To respond to your enquiry; Performance of a contract
To administer the relevant competition; Performance of a contract; includes but not limited to affiliations, sanctioning, and the County Cups
To administer the Disciplinary Process Performance of a contract; includes sharing names of witnesses through the provision of statements
To send information to you; Performance of a contract
To fulfil any contract that we may enter into with you; Performance of a contract
For research purposes; Legitimate interest: this includes but is not limited to FA grassroots surveys, improving your experience, identifying needs for facility   improvement, establishing reasons for decreasing participation, and Equality Monitoring.  Surveys and stakeholder consultation are also carried   out to assist with informing future strategy. Where applicable, this research may be conducted by third parties.   
To work towards the Intermediate Equality Standard Legitimate interest: an equality audit survey is carried out as part of the work towards the Intermediate Equality Standard, to support Kent FA   in identifying gaps in provision and developing an Equality Action Plan. Analysed and anonymised data is shared with external verifiers for the   standard.  
To send marketing information to you in accordance with the provisions set out below; or Consent: we will only send direct marketing if the individual has consented to receive this information via our e-newsletter opt-in form or through Player Registration.  
To offer development and progression opportunities. Legitimate interest: we will send registered Coaches, Referees and Club Officials details of upcoming relevant education opportunities, e.g., training courses and CPD events, as well as paid and voluntary career opportunities where relevant, unless they have informed us that they do not wish to receive this information.  
To publish your views or comments on this Site, any other website operated by us or our subsidiaries or in other media.

Legitimate interest: Where you have posted comments on social media sites, we may re-post them on our website or social media platforms because the information is already in the public domain.  If an individual does not want us to do this, they can object to this processing by contacting us via the details in the Contact Us section below.  

Consent; where you have liaised with us privately, we will only publish your views with your consent.   

Sending out County FA information and updates Performance of a contract
Sharing referee data Legitimate Interest; with clubs, leagues, County Associations and Referee Associations. If a referee does not want this, they can object by contacting us using the details in the Contact Us section below.
To assist players to find opportunities within local teams and allowing local teams to find players Consent; players and teams can register to use the Perfect Match service and give their consent by registering for their details to be shared with other users of the service. 
Complying with health and safety obligations, including in relation to the safeguarding of children and adults at risk Legal obligation/ necessary for the performance of a task carried out in the public interest; for the purpose of safeguarding the welfare of children and adults at risk involved in football across the County.

This includes the sharing of information regarding DBS, qualifications and concerns about children with Clubs, Leagues, the FA and statutory agencies.  
Sharing anonymised data with a funding partner as condition of grant funding e.g. Local Authority Legitimate Interest: the County FA has a legitimate interest to run the organisation efficiently and as it sees fit. Applications for funding is a purpose that benefits the County FA, participants and its members.
Publishing club and league contact details in our annual handbook and/or App Performance of a contract; for the purpose of administering leagues and clubs, along with county competitions. This data is deleted each season and renewed with your annual consent.

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
 
Please note that we may process your personal information without your knowledge or consent, in compliance with the relevant laws, where this is required or permitted by law.
 
Direct Marketing
 
We would like to send you marketing information, by e-mail, or SMS. In addition, selected third parties (including the FA, FA Partners as shown on the Site, and other commercial partners) would like us to share their marketing information, by e-mail, or SMS. We will only do this if you have given your consent to your personal data being used in this way (either when you submit your details to us or at a later stage). You can update your marketing preferences by writing to preferences@kentfa.com.
 
Sharing your personal data
 
Please see above for the process by which personal data is collected.  Once collected, we will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so (e.g it is necessary to protect the rights, property, or safety of our participants, members or affiliates, or others). In particular, we pass information to the FA for affiliation and other reporting purposes. 
 
We may also share your personal data with our affiliates and sub-contractors. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We only permit third parties to process your personal data for specified purposes i.e. to send out our newsletters and in accordance with our instructions.
 
We use a processing company to send our e-newsletters and your email address will be shared with this company (Oporto Sports) for this purpose only. They commit to respect the security of your personal data and to treat it in accordance with the law.
 
We will share referee’s information with local Referee Associations.
 
We will never share your personal details with partners, suppliers or commercial third parties. 
 
We have access to the Whole Game System, please see the privacy policy relevant to it here: https://www.thefa.com/public/privacy/wgs-portal.
 
International Transfers
Some of our suppliers or third parties may process our personal data outside the European Economic Area (EEA) such as our website and email providers. We review the data protection terms of these suppliers to ensure that your personal data will only be transferred out of the EEA, if sufficient appropriate safeguards are in place.
 
Protection of your personal data
We are committed to protecting your privacy and have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Details of these measures are available upon request. Third parties will only process your personal information on our instructions and where they have agreed to treat the information confidentially and to keep it secure.
 
However, the nature of the internet is such that the data may in some circumstances flow over networks without full security measures and could be accessible to unauthorised persons. We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
 
Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Generally, we keep personal data on our participants, members and other website users while they are signed up to the County FA or any of our website services. We will delete this data 24 months after an individual has ended their membership or affiliation, or sooner if specifically requested and we are able to do so. 
 
We use FA sites to store personal data and the FA process this data for as long as the individual is an active user of the sites and for five seasons after this.  The data will then be held as inactive for a further 3 months before being deleted.  For further information on the FA sites, please see the FA’s Privacy Notice at http://www.thefa.com/public/privacy.  
 
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.
 
Where we process personal data in connection with performing a contract or for a competition, we keep the data for seven years from your last interaction with us or from when the contract ends.  
 
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
 
Cookies
 
When you visit our website, we may collect, process and use information about you which may not personally identify you, but which may be helpful for improving the operation of the website. Such information may be collected through "traffic data" and may entail the use of "cookies", "IP Addresses" or other numeric codes used to identify your computer. You can delete cookies or configure your computer to reject them, although this may disable the website’s ability to manage individual sessions.
 
Third Party Links
 
This website may contain links to other sites. Please be aware that we are not responsible for the privacy practices of these sites. We encourage our users to be aware when they leave this website and to read the privacy statements applicable on those sites. This privacy policy does not apply to information collected on third parties’ sites.
 
Your Rights
 
All data subjects have the right to:
1. Request access to your personal data.
2. Request rectification of any of your personal data that is inaccurate or incomplete.
3. Request erasure of your personal data where there is no good reason for us continuing to process it. 
4. Object to processing of your personal data for direct marketing, or where we are processing on the grounds of a legitimate interest and that interest is overridden by your rights and freedoms.
5. Request restriction of processing of your personal data while we establish the data's accuracy, verify an overriding interest to object to processing, where our use of the data has been unlawful but you do not want us to erase it or where you need us to hold the data to establish, exercise or defend legal claims. 
6. Request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format. 
7. Withdraw consent at any time where we are relying on consent to process your personal data. 
8. Complain at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues. 
 
Where you seek to assert any of your rights listed above, we will endeavour to respond to you without undue delay and in any event ordinarily within one month of receipt of the request. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests. In this scenario, we will inform you of any such extension within one month of receipt of your request, together with the reasons for the delay. 
 
You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
 
We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.
 
We will communicate any rectification, erasure or restriction of processing of your personal data to each recipient to whom it has been disclosed, unless this proves impossible or involves disproportionate effort.
 
Your duty to inform us of changes 
 
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes.
 
Contact Us
 
If you have any queries about this Privacy Policy, wish to stop direct marketing by the FA, its subsidiaries or third parties or you wish to access or update your information please email preferences@kentfa.com or write to us at Kent FA, Invicta House, London Road, Ditton, Kent, ME20 6DQ.